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appropriate. Where petitioners presented contemporaneous
documents, we have allowed the claimed amounts after adjusting
for any disparities between the documents and Dr. Rinker’s
testimony and for computational errors. Similarly, where the
original documents were lost by Mr. Hertz, but where petitioners
presented credible reconstructions of their expenses which carry
their burden of proof, we have allowed the claimed amounts after
adjusting for minor errors and discrepancies.
B. Particular Deductions
1. Office Liability Insurance
Dr. Rinker testified that she paid for tort liability
insurance for her medical office. Dr. Rinker testified that
during 1999 her expenses for liability insurance may have been
about $250. Premiums paid for business liability insurance are
deductible business expenses. Sec. 1.162-1(a), Income Tax Regs.
Under Cohan v. Commissioner, supra at 544, we allow a deduction
of $125.
2. Malpractice Insurance
Dr. Rinker submitted a receipt for medical malpractice
insurance in the amount of $2,385. The receipt was marked as
“paid” and dated January 31, 1999, and the policy apparently
covered February 1, 1999, through February 1, 2000. Medical
malpractice insurance premiums are deductible business expenses.
Sec. 1.162-1, Income Tax Regs. Although the year-long insurance
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